October 2019

In an October 28, 2019 memorandum for Secretary of Commerce Wilbur Ross, the Department of Commerce’s Office of Inspector General (IG) issued a “management alert” over concerns about the “lack of transparency that contributes to the appearance of improper influence in decision-making” for the Section 232 steel and aluminum tariff exclusion process. While not requesting…

The Office of the U.S. Trade Representative (USTR) has announced that it is seeking public comment on its consideration of extending certain product exclusions it granted in December 2018 in the ongoing trade dispute with China [update: USTR Federal Register notice of October 31, 2019]. These exclusions were part of the first round of…

The Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced a new “humanitarian mechanism” to ensure transparency in humanitarian trade with Iran. According to OFAC, this mechanism “will help the international community perform enhanced due diligence on humanitarian trade to ensure that funds associated with permissible trade in support of the Iranian…

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a long-awaited final rule prohibiting the opening or maintaining of correspondent accounts in the United States for, or on behalf of, Iranian financial institutions, and the use of foreign financial institutions’ correspondent accounts at covered U.S. financial institutions to process transactions involving Iranian…

The Office of the U.S. Trade Representative (USTR) announced today more Section 301 tariff exclusions for certain imported Chinese products appearing on List 3. These products have been subject to Section 301 tariffs since September 24, 2018. The USTR determined that 83 specific product descriptions will be excluded from the tariffs, covering 95 separate exclusion…

Merely nine days after implementing sanctions on Turkey for its military action in northeast Syria (see Trump and Trade Update of October 15, 2019), President Donald Trump announced that he was lifting those sanctions due to the continuing ceasefire along the border. The president stated that Turkey would be halting its offensive and make…

The Office of the U.S. Trade Representative (USTR) has announced that it will begin accepting tariff exclusion requests on October 31, 2019, for imports of Chinese goods subject to a 15 percent tariff (Tranche/List 4 tariffs), which went into effect on September 1, 2019. This list encompasses products on List 4A of approximately…

The Department of Commerce’s Bureau of Industry and Security (BIS) further tightened U.S. sanctions on Cuba “for its repression of the Cuban people and its support of the Maduro regime in Venezuela.” Overall, the United States maintains a comprehensive embargo on trade with Cuba, and the export and reexport to Cuba of items subject to…

On October 14, 2019, President Donald Trump announced U.S. economic sanctions directed at the government of Turkey in response to Turkey’s military action in northeast Syria, “including but not limited to indiscriminate targeting of civilians, targeting of civilian infrastructure, targeting of ethnic or religious minorities, or targeting or other actions that undermine the continued counterterrorism…

On October 11, 2019, in remarks to the press, President Donald Trump announced that the United States and China’s trade negotiators had “agreed in principle” to address issues involving intellectual property, financial services and agricultural sales between the two countries. In this “phase one” agreement, China agreed to purchase between $40 billion to $50…